[CG73988] NRCG and the exemptions: Disposals from 6 April 2019: Interactions with exit charges: Deemed disposals on exiting the UK
Deemed disposal under section 25(3)
Where a person has ceased to trade through a UK branch or agency, they are deemed (under TCGA92/S25) to have made a disposal of an asset (see CG25530). TCGA92/S25ZA applies in this case. Where the asset in question is an interest in UK land and a non-resident CG charge or loss would accrue to the person on the deemed disposal, the gain or loss will not accrue at the time of the deemed disposal, but when all or part of the interest in question is subsequently disposed of – at which point it will be treated as a non-resident CG chargeable gain or allowable loss.
The person may elect for TCGA92/S25(3) not to have effect if that is advantageous to them.